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Glossary

Substitute Scanning (BSI TR-03138)

Substitute scanning is a legally compliant process for digitizing paper documents in Germany. After scanning, the original may be destroyed without losing the evidentiary value of the resulting digital document.

The basis for this process is the technical guideline BSI TR-03138, also known as RESISCAN. This guideline defines requirements for technology, organization, and documentation to ensure the integrity of the digital copy.

RESISCAN: What Does the Acronym Stand For?

The term “substitute scanning” is often abbreviated as RESISCAN, a concept introduced by Germany’s Federal Office for Information Security (BSI). RESISCAN stands for REchtlich SIcheres ersetzendes SCANnen (Legally Secure Substitute).

The name sums up the core idea: It’s not just about scanning, it’s about creating a trustworthy digital record.

The Technical Guideline TR-03138 as a Roadmap

To address uncertainty among users, the BSI developed Technical Guideline TR-03138 as a clear roadmap. It defines the minimum technical and organizational requirements for the substitute scanning process. Only by following this plan can the original document be legally destroyed.

How Does RESISCAN Ensure the Credibility of Digital Documents?

The guideline (BSI TR-03138) ensures that the digital image is visually and textually identical to the original and that it has not been tampered with during its transfer to the digital archive. This integrity safeguard is essential.

TR-03138 specifies in detail:

  • Scanning process: How to prepare documents for the scanning line and what checks to perform during scanning.
  • Technical requirements: Which quality standards scanners and software must meet to prevent data loss.
  • Authenticity: The use of qualified electronic seals or timestamps proves that the document has remained unchanged since a specific point in time.
  • Transfer record: This protocol accompanies the document, certifying that the scanning process was properly executed and fully traceable.
  • Destruction: Clear rules for legally compliant and data-protected disposal of the paper original (e.g., according to DIN 66399).

Is BSI TR-03138 Mandatory for Businesses?

Here’s an important distinction regarding substitute scanning:

  1. Public authorities and courts: Compliance with TR-03138 is often legally required because it defines the “state of the art” for electronic file management (e-files).
  2. Businesses: The guideline is not legally mandatory but is considered an established standard.
    However, note this: Tax authorities require a traceable and secure digitization process under the GoBD (Principles for Proper Management and Storage of Books, Records, and Documents).
    • Following TR-03138 is the simplest and safest way to demonstrate GoBD compliance.

Adhering to the guideline is therefore a strong argument for legal certainty and should not be overlooked.

Process Documentation: Proof of the RESISCAN Workflow

The core of substitute scanning is the process documentation. This central document describes the scanning workflow from start to finish and serves as proof of the digital copy’s credibility. It must include:

  • Responsibilities: Who is authorized to perform which steps?
  • Technology: Which hardware and software are used?
  • Quality checks: How is readability and completeness ensured?
  • Archiving: How are data stored, secured, and eventually deleted?

The process documentation makes the entire workflow transparent and verifiable for auditors or courts at any time.

Where Is RESISCAN a Game Changer?

RESISCAN is essential wherever large volumes of documents need to be stored for long periods:

  • Accounting and finance: GoBD-compliant digitization of invoices and receipts with subsequent destruction.
  • Human resources: Archiving of personnel files, contracts, and certificates.
  • Public administration: Transition to electronic files in line with e-government initiatives.
  • Healthcare: Long-term, secure storage of patient records.

With BSI TR-03138 and substitute scanning, you can say goodbye to paper overload and take the first step toward optimized, fully digital processes.

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